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I left USA in 2019, but did not inform Bank of America about this. I am currently in Canada, continue to operate my BoA account for payments, and have substantial balance in the bank account in US.

I need to "communicate with an associate" in order to initiate transfer to Canada. I am nervous, could they freeze my account or assets for not letting them know in time. It has been over an year. I was on Visa in both countries.

Would it be safe if someone knows about this at the bank?

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    My son, a US citizen, has lived and worked in the UK and NL for almost four years. He maintains several US accounts at US banks. He receives no paper communications from the institutions, and uses only online and email contact methods. He is scrupulous about filing US income tax returns, and reporting whatever info relates to these accounts. One of the institutions writes renter's insurance for his NL flat. All of this leads me to think maintaining the account is not contrary to US law. You might want to read the Bank's T&C to see if they address this. Dec 15, 2020 at 15:59
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    Find and read the Terms and Conditions of the BoA account. Dec 15, 2020 at 16:03
  • I’m voting to close this question because it is essentially opinion-based and as it stands there are too many potential variables to be able to respond. The OP needs to read the T&C of their BofA account and if necessary thereafter edit the question to clarify the exact problem pertaining to their situation as related to the relevant T&C.
    – Traveller
    Dec 16, 2020 at 17:00
  • I think the exact problem pertaining to their situation is fear, in particular fear regarding the sharing of residency information with their banking institution.
    – ouflak
    Dec 16, 2020 at 21:25
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    From my experience in related situations (not with a US institution though), being forced to close the account is a real possibility but seeing your assets freezed seems unlikely. You might be given a deadline or asked to provide a means to transfer the money elsewhere.
    – Relaxed
    Dec 20, 2020 at 22:13

3 Answers 3

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This is a valid question that has real-world repercussions. It bears on the requirements of the US FATCA law and what potential actions one can expect from banks in the US, as well as in Canada, in the OP’s case. Unless you are resident in Iran, or some small country in Africa whose name I forget, all other nations have signed treaties with the US to abide by FATCA reporting requirements, which are onerous. For example, I notified my US bank that my portable number was now a French number (because it was tiring switching SIM cards for two-factor logins to my bank’s site). They thanked me for the update, and told me they would be closing my account in thirty days because I was resident in a foreign country. Here in France, I was working on a business venture and, with an accountant, made a business proposal for a loan to my bank here. I have dual-citizenship US & EU, so my bank here knows me as an EU citizen. Everything was going well, until they noticed that I had funds coming from the US. They declined categorically to do business with me because the US funding imposed unreasonable requirements on them. I’m sure if I was Apple, it would be worth the risk, but not in my case. So this question is pertinent to all American expats. The FATCA issue is complex, so I suggest you seek out professional assistance.

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In most cases, banks aren't looking for reasons to close your account, but they may judge keeping it to be unduly risky depending on information you provide them. For example, a bank in country A providing service to a resident of country B might be required to comply with all relevant regulations of country B. As long as you pay all appropriate taxes, you aren't violating any law by keeping an account in country A. However, if the bank doesn't normally comply with the banking regulations of country B (or isn't familiar with them), the bank may close your account upon learning that you are now a resident of country B.

In the specific case of a US citizen or US resident alien with a non-US bank account: If at any point you have over $10,000 total in non-US bank account(s), you personally must submit the FBAR form(s) or face large penalties. In addition, in most cases your non-US bank must comply with FATCA reporting to the US tax authority, for which they will require your SSN or TIN. Some non-US banks will avoid serving US citizens or residents in order to avoid such obligatory reporting.

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In my case, I am able to operate a BoA account while not living in the US. I get every 2 years a form, where I have to declare per post as a "non-resident alien" that this account is still mine. I also need to do occasional minimal transfers from one sub-account to another. So my account stays active, and the savings are still there.

The biggest problem, comes with the fact that without a US address, you cannot get a debit card, and without a debit card you cannot do wire transfers. Also, you need a US phone number for one-time-authentication. If you don't have these, can maintain your account, but your money will be stuck in your account and you won't be able to transfer it.

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